Clarity Privacy Notice

Privacy Notice

Last Update: 02/02/2023

This Privacy Notice (this “Notice”) explains how we collect, use, share, and protect the information that you provide to us through our services. By using our services, you agree to the collection and use of information in accordance with this Notice.

Clarity Health Technologies, Inc (“we”, “us”, “the Company”, “Clarity”, any parent entity or subsidiary) is committed to keeping your personal data confidential. We use your data solely in the context of providing a telehealth platform (the “Platform”) and associated services and Products (defined below) (collectively, the Platform and the associated services and Products are the “Services”) through which you can access Clarity’s support to people undergoing neurological disorders. As part of the Services, we may collect and process personally identifiable information, including Protected Health Information (as this term is defined under the Health Insurance Portability and Accountability Act (“HIPAA”).

What personnal data do we collect ?

At Clarity, we gather and process a variety of information from or about you, depending on which of our Services you use. This information may include:

  • Personal data and other information that you (and others) provide to us. This could include your name, email address, phone number, user profile information, transaction details, and contact information when you interact with our Services. It may also include optional information such as body features, language, cognitive abilities, health-related data, and other information you (or your guardian, relative, or professional) provide voluntarily.
  • Information that is collected automatically when you use our Services, such as the type of device you’re using, its configuration, browser, performance, and the features you interact with. We may also receive information about you from third-party services if you choose to use them to access our Services.
  • Aggregated data such as statistical or demographic data. This data is derived from your personal data, but is not considered personal data by law since it cannot directly or indirectly identify you. Please note that our Services are not intended for children, and we do not knowingly collect data relating to children.

In order to provide you with a good experience when you use our website and mobile app, we use cookies to distinguish you from other users. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or mobile device if you agree. This helps us to personalize our content for you, remember your preferences, and improve the way our website or mobile app works. We may also share this information with third parties for this purpose. Depending on which of our Services you use, we may use the following types of cookies: strictly necessary cookies, analytical/performance cookies, functionality cookies, and targeting cookies. You can set your browser or mobile app to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of our website or mobile app may become inaccessible or not function properly.

Please note that our Services are not intended for children, and we do not knowingly collect data relating to children.

How do we use personnal data ?

We may process your Data for legitimate business purposes in compliance with applicable law if we provide you with a Product. We will collect and remotely process your Data regarding the use of the Product, and transmit the usage data to your healthcare provider if requested. This is done with your consent. The purposes for which we may process your Data may include providing Services fulfilling our obligations to you under the Terms of Use, communicating with you and managing your Account, storing and tracking your data within our system, responding to lawful requests from public and government authorities, protecting our rights and those of you and others, providing technical support, enforcing and ensuring your compliance with our Terms of Use, managing and improving our operations and the Platform and Sites, managing payment processing, evaluating the quality of service you receive, keeping our Platform and Sites safe and secure, sending information about changes to our terms, conditions, and policies, allowing for connection with or the sharing of Data with healthcare providers, conducting surveys, and carrying out research, study, or evaluation programs. All research, study, and evaluation programs are done in a way that respects your privacy, and all conditions required by applicable regulations are met.

Additionally, we may analyze aggregated statistics in such a way as to guarantee the anonymity and respect of the privacy of our Users

How do we share personnal data ?

Clarity does not share, sell, or otherwise disclose your Data for purposes other than those outlined in this Privacy Notice. We may use or disclose aggregated or pseudo-anonymized information about Users, and information that does not identify any individual, without restriction.

It is important that the Products supplied by Clarity are employed correctly in order to ensure that the Data collected is precise. The reliability and precision of the Data is only guaranteed when no one other than our personnel or our approved Partner’s personnel interferes. To make sure the confidentiality, accuracy, durability, and reliability of the Data stored in our care is preserved, we have taken appropriate technical precautions.

In order to provide and support our Services, certain information that we have about you is shared in certain circumstances. When you and others use our Services, the following may have access to information about you:

  • Developers, support staff, and other providers of online content on our Services. You may interact with third-party content, games, apps, and other experiences through our Services. To provide you with the experiences that you’ve requested, we may share information about you with these partners, such as:
    • Information in your Clarity profile and about how you use our Services (e.g., we may provide a third-party games provider with your user id or similar).
    • Any other information that you have chosen to share with the third party through your use of the Services.
    • Sharing within related companies. Depending on which services you use, we may share information with companies part of the same group of companies that Clarity is part of, or that become part of that group, such as Clarity Technologies SASU., our French subsidiary.
  • We may share the information we collect with vendors, service providers, researchers, and other partners who work at our direction in order to support the Services (including hosting, managing orders, facilitating payments, analyzing the usage of our Services, processing credit card payments, providing customer service, or sending electronic communications).
  • In the event of a merger, acquisition, or bankruptcy, information from or about you and your device may be transferred to another company.
  • Additionally, we may share information with law enforcement or in response to legal requests, as outlined in Section 7.
  • We also provide developers with de-identified or aggregate data. De-identified data is information where we have removed any personally identifiable data, such as your name and other data that could be used to identify you. Aggregate data is data that has been combined with other data so that it does not identify any specific person. For instance, we may provide developers with aggregated statistics about the number of people from a particular region that use our Services, enabling developers to create content or features tailored for people in that market.

How the Clarity companies work together and share data ?

Clarity shares infrastructure, systems, and technology with other Clarity companies to provide an innovative, relevant, consistent, and safe experience across all Services that you use.

As part of our global services, Clarity shares personal data collected among Clarity companies as its French subsidiary Clarity Technologies SASU.

We share information globally, both internally within Clarity and externally with our partners to fully provide the Services you are entitled to receive based on the Service you have purchased or subscribed to and/or otherwise are entitled to receive. Information controlled by Clarity will be transferred or transmitted to, or stored and processed in the United States, France, and/or other countries outside of where you live for the purposes as described in this policy. These data transfers are necessary for us to globally operate and provide our Services to you. We utilize standard contract clauses commonly used in the countries we operate.

Data retention and deletion

When you sign up to use our Services, we store certain data that identifies you until it is no longer necessary to provide our Services. This can depend on a variety of factors such as the type of data, why it is collected and processed, and applicable legal or operational retention requirements. In some cases, for example, we may retain certain purchase information for accounting and tax purposes even after you have deleted your account. Once you delete an account with us, we separate the personally identifiable information (PII) associated with the data that you provided and the data we collected during your use of the Services. After this separation, it is not possible to link either the data you provided or the data we collected back to your PII. We then retain the anonymous data generated from the combined data.

Depending on the legal basis of collection, the origin of the data collection, and the intention of the collection, individuals may be entitled to a variety of rights related to their data. These rights may include:

  • Access and correction: Individuals may request access to their data and, if they believe the information is inaccurate, they may request for it to be corrected.
  • Withdrawal of consent: At any time, individuals may withdraw their consent for their data to be processed. Any withdrawal of consent will only be applied to data collected or used in the future, and not to any data that has already been collected or used.
  • Objection: Individuals may object to the processing of their data, provided they can provide a legitimate reason. If an individual is objecting to the processing of their data for commercial purposes, then a legitimate reason is not necessary.
  • Right to be forgotten: Individuals have the right to have their data erased after a certain period of time.
  • Limitation of processing: Individuals may request that their data be subject to limited processing in certain circumstances.
  • Right to portability: you may request a copy of the Data that you have provided to Clarity or that Clarity transfer that Data to another entity.
  • Right not to be subject to automated individual decisions: if you are subject to a decision taken about you solely by technological means and without any human involvement (e.g. algorithmic decisions based on your Data), you may request to see the reasoning behind the decision and discuss it with a person.

For any inquiry, please contact us at :

In certain circumstances, if it is judged to be necessary and reasonable, we may make available your Data to meet legal requirements or enforceable government requests, or as mandated by law. Additionally, we may work with third parties to investigate activities that break the terms of this Privacy Notice or the Terms of Use, or to take legal action against someone who may be breaking the Terms of Use or causing intentional or unintentional harm or interference to the rights or property of Clarity or any third party, including other users of our Services.

Changes to this policy

It is essential that you stay informed of any modifications to this Privacy Notice as we may update it from time to time. All updates to this Notice will be published on the Clarity Site and Platform related to it. Any modifications made to this Notice will take effect immediately upon being posted and will be applicable to all data we use, possess, and reveal. If you keep utilizing the Services and Sites after being made aware of the changes, you are consenting to those changes.

How can you exercise the rights provided to you under the GDPR?

If you are living in the European Union or some other countries in Europe, the General Data Protection Regulation (GDPR) could be relevant to the information that we collect, store and process from you. According to the GDPR, you have the right to:

  • Access your Data
    • You have the right to request from Clarity whether any personal data of yours is being processed and, if so, information including but not limited to the purpose of the processing and the categories of personal data that Clarity has about you. When requested, Clarity is obligated to provide you with a copy of the data that is being processed.
  • Rectify your Data
    • Should it come to your attention that certain personal data of yours is inaccurate and being processed by Clarity, you have the right to obtain a rectification or in some cases a right to have incomplete data completed.
  • Port your Data
    • If the legal basis for processing of personal data is either (i) consent or (ii) fulfillment of a contract between you and Clarity, you have the right to receive data that you have provided us in a commonly used and machine-readable format and have the right to transmit it to another controller.
  • Request the disassociation and erasure of your personally identifiable information (PII) when certain criteria are met.
    • This includes, but is not limited to, when the data is no longer necessary in relation to the purpose for which it was originally collected, if you withdraw consent, if you object to the processing and there are no overriding legitimate grounds for the processing, or if the personal data have been unlawfully processed.
  • Restrict and object to certain processing of your data when,
    • for instance, you contest the accuracy of the personal data or if Clarity no longer needs certain data for the purpose of processing.

Contacting us

If you have any questions or concerns after reading this Privacy Notice, please do not hesitate to contact us at We appreciate your feedback.